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Tax Controversy

Published: September 2019


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  • 1.

    What is the relevant legislation relating to tax administration and controversies? Other than legislation, are there other binding rules for taxpayers and the tax authority?

  • 2.

    Relevant authority
    What is the relevant tax authority and how is it organised?

  • 3.

    Compliance with tax laws
    How does the tax authority verify compliance with the tax laws and ensure timely payment of taxes? What is the typical procedure for the tax authority to review a tax return and how long does the review last?

  • 4.

    Types of taxpayer
    Are different types of taxpayers subject to different reporting requirements? Can they be subjected to different types of review?

  • 5.

    Requesting information
    What types of information may the tax authority request from taxpayers? Can the tax authority interview the taxpayer or the taxpayer’s employees? If so, are there any restrictions?

  • 6.

    Available agency action
    What actions may the agencies take if the taxpayer does not provide the required information?

  • 7.

    Protecting commercial information
    How may taxpayers protect commercial information, including business secrets or professional advice, from disclosure? Is the tax authority subject to any restrictions concerning what it can do with the information disclosed?

  • 8.

    Limitation period for reviews
    What limitation period applies to the review of tax returns?

  • 9.

    Alternative dispute resolution
    Describe any alternative dispute resolution (ADR) or settlement options available?

  • 10.

    Collecting overdue payments
    How may the tax authority collect overdue tax payments following a tax review?

  • 11.

    In what circumstances may the tax authority impose penalties?

  • 12.

    How are penalties calculated?

  • 13.

    What defences are available if penalties are imposed?

  • 14.

    Collecting interest
    In what circumstances may the tax authority collect interest and how is it calculated?

  • 15.

    Criminal consequences
    Are there criminal consequences that can arise as a result of a tax review? Are these different for different types of taxpayers?

  • 16.

    Enforcement record
    What is the recent enforcement record of the authorities?

  • 17.

    Involvement of third parties
    Can a tax authority involve or investigate third parties as part of the authority’s review of a taxpayer’s returns?

  • 18.

    Cooperation with other authorities
    Does the tax authority cooperate with other authorities within the country? Does the tax authority cooperate with the tax authorities in other countries?

  • 19.

    Hardship procedures
    Do any special procedures apply in cases of financial or other hardship, for example when a taxpayer is bankrupt?

  • 20.

    Voluntary disclosure and amnesties
    Are there any voluntary disclosure or amnesty programmes?

  • 21.

    Rules protecting taxpayers
    What rules are in place to protect taxpayers?

  • 22.

    Requesting information
    How can taxpayers obtain information from the tax authority? What information can taxpayers request?

  • 23.

    Tax authority governance
    Is the tax authority subject to non-judicial oversight?

  • 24.

    Competent courts
    Which courts have jurisdiction to hear tax disputes?

  • 25.

    Lodging a claim
    How can tax disputes be brought before the courts?

  • 26.

    Combination of claims
    Can tax claims affecting multiple tax returns or taxpayers be brought together?

  • 27.

    Pre-claim payments
    Must the taxpayer pay the amounts in dispute into court before bringing a claim?

  • 28.

    Cost recovery
    To what extent can the costs of a dispute be recovered?

  • 29.

    Third-party funding
    Are there any restrictions on or rules relating to third-party funding or insurance for the costs of a tax dispute, including bringing a tax claim to court?

  • 30.

    Court decision maker
    Who is the decision maker in the court? Is a jury trial available to hear tax disputes?

  • 31.

    Time frames
    What are the usual time frames for tax trials?

  • 32.

    Disclosure requirements
    What are the requirements concerning disclosure or a duty to present information for trial?

  • 33.

    Permitted evidence
    What evidence is permitted in a tax trial?

  • 34.

    Permitted representation
    Who can represent taxpayers in a tax trial? Who represents the tax authority?

  • 35.

    Publicity of proceedings
    Are tax trial proceedings public?

  • 36.

    Burden of proof
    Who has the burden of proof in a tax trial?

  • 37.

    Case management process
    Describe the case management process for a tax trial.

  • 38.

    Can a court decision be appealed? If so, on what basis?

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